MSBA comment letter in response to new rulemaking authorities

The MSBA submitted a comment letter to the CFPB in response to the RFI to assess adopted regulations and new rulemaking authorities.

Many of the MSBA members are classified as remittance transfer providers (“RTPs”) under the Remittance Rule (the “Rule”) and are therefore directly impacted by the Rule. While the MSBA members understand the underlying policy concerns which prompted the implementation of the Rule, MSBA respectfully submits that the operational burdens, unintended consequences, and costs it creates outweigh the intended benefits.